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The government has substantially revised draft Finance Bill 2013 legislation amending anti-avoidance rules dealing with the transfer of assets abroad (Chapter 2, part 13, Income Tax Act 2007) and the attribution of gains made by non-UK tax resident companies that are closely controlled by UK participators (section 13, Taxation of Chargeable Gains Act 1992). This is a detailed legal update on the revised version published on 11 December 2012.

On 11 December 2012, HMRC published revised draft legislation for inclusion in the Finance Bill 2013 to amend anti-avoidance rules dealing with the transfer of assets abroad (Chapter 2, Part 13, Income Tax Act 2007) and the attribution of chargeable gains realized by non-UK tax resident companies that are closely controlled by UK participators (section 13, Taxation of Chargeable Gains Act 1992). The government has made significant changes to meet criticism that the original draft legislation did not make the rules compliant with EU law, but it is still unclear whether compliance will be achieved.

The opinions expressed do not constitute investment advice and specialist advice should be sought about your specific circumstances.